Privacy Policy

1. Introduction

Pogon Public Speaking Academy ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website pogonupsoa.com and use our services.

This policy applies to all information collected through our website, email communications, text messages, and other related services (collectively, the "Service").

By accessing or using our Service, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

2. Information We Collect

2.1 Personal Information You Provide

We may collect personal information that you voluntarily provide to us when you:

• Register for our courses or workshops
• Subscribe to our newsletter
• Contact us through our website forms
• Participate in surveys or feedback requests
• Apply for employment with us
• Interact with us on social media

This information may include:

• Name and contact information (email address, phone number, mailing address)
• Professional information (company name, job title, industry)
• Educational background and experience
• Payment information (processed through secure third-party providers)
• Communication preferences
• Course-related information and assessments

2.2 Information Automatically Collected

When you visit our website, we may automatically collect certain information about your device and usage patterns, including:

• IP address and location data
• Browser type and version
• Operating system
• Pages visited and time spent on pages
• Referring website
• Device identifiers

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information about our cookie usage, please refer to our Cookie Policy.

3. How We Use Your Information

We use the information we collect for various purposes, including:

3.1 Service Provision

• Providing and maintaining our services
• Processing course registrations and payments
• Delivering educational content and materials
• Providing customer support and responding to inquiries
• Sending important updates about our services

3.2 Communication and Marketing

• Sending newsletters and promotional materials (with your consent)
• Informing you about new courses and services
• Conducting surveys and market research
• Personalizing your experience with our content

3.3 Business Operations

• Analyzing website usage and improving our services
• Preventing fraud and ensuring security
• Complying with legal obligations
• Protecting our rights and interests

4. Legal Basis for Processing (Canadian Privacy Laws)

Under Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), we process your personal information based on the following legal grounds:

• Consent: Where you have provided explicit consent for specific purposes
• Contract Performance: To fulfill our contractual obligations to provide services
• Legitimate Interests: For our legitimate business interests, provided they don't override your privacy rights
• Legal Compliance: To comply with applicable Canadian laws and regulations

5. How We Share Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

5.1 Service Providers

We may share your information with trusted third-party service providers who assist us in operating our business, including:

• Payment processors
• Email marketing platforms
• Website hosting and analytics providers
• Customer relationship management systems
• Video conferencing platforms

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required by law or in good faith belief that such action is necessary to:

• Comply with legal obligations or court orders
• Protect and defend our rights or property
• Prevent fraud or other illegal activities
• Protect the safety of our users or the public

5.3 Business Transfers

In the event of a merger, acquisition, or sale of business assets, your information may be transferred as part of that transaction, subject to appropriate privacy protections.

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive data in transit and at rest
• Regular security assessments and updates
• Access controls and employee training
• Secure payment processing through PCI-compliant providers
• Regular backup and disaster recovery procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specific retention periods include:

• Course participants: 7 years after course completion for educational records
• Newsletter subscribers: Until you unsubscribe or request deletion
• Website analytics: 26 months for Google Analytics data
• Financial records: 7 years as required by Canadian tax laws
• Marketing communications: Until consent is withdrawn

When personal information is no longer needed, we securely delete or anonymize it.

8. Your Privacy Rights

Under Canadian privacy laws, you have the following rights regarding your personal information:

8.1 Access and Correction

• Request access to your personal information we hold
• Request correction of inaccurate or incomplete information
• Receive information about how your data is being used

8.2 Withdrawal of Consent

• Withdraw consent for marketing communications at any time
• Opt out of non-essential cookies through our cookie settings
• Request deletion of your personal information (subject to legal requirements)

8.3 Complaints

• File a complaint with us about our privacy practices
• Contact the Office of the Privacy Commissioner of Canada if unsatisfied with our response

To exercise these rights, please contact us using the information provided in Section 11.

9. International Transfers

Some of our service providers may be located outside of Canada. When we transfer your personal information internationally, we ensure appropriate safeguards are in place, including:

• Contractual data protection clauses
• Adequacy decisions by the Privacy Commissioner
• Industry-standard security measures
• Regular monitoring of data handling practices

We primarily use service providers located in Canada and countries with adequate privacy protections.

10. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

Parents or guardians who believe their child has provided personal information to us should contact us immediately.

11. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

We will respond to your inquiry within 30 days of receipt.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you of material changes via email or website notice
• Obtain your consent for material changes that affect your rights
• Maintain previous versions for reference

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Province of Quebec and the laws of Canada applicable therein. Any disputes arising under this policy will be subject to the exclusive jurisdiction of the courts of Quebec.

14. Acknowledgment

By using our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this policy, please do not use our services.